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Swen Capital Partners

PRI reporting framework 2019

Basic information [OO 01 - 09] Asset class implementation gateway indicators [OO 10 - 12] Peering questions [OO LE 01 - HF 01]

Strategy and Governance

Investment policy [SG 01 - 04] Objectives and strategies [SG 05 - 06] Governance and human resources [SG 07 - 08] Promoting responsible investment [SG 09 - 11] Outsourcing to fiduciary managers and investment consultants [SG 12] ESG issues in asset allocation [SG 13 - 15] Asset class implementation not reported in other modules [SG 16 - 17] Innovation [SG 18] Communication [SG 19]

Indirect – Manager Selection, Appointment and Monitoring

Selection [SAM 02 - 03] Appointment [SAM 04] Monitoring [SAM 05 - 07] Outputs and outcomes [SAM 08 - 09]

Confidence building measures

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Confidence building measures

CM1 01. Assurance, verification, or review

01.1. Indicate whether the reported information you have provided for your PRI Transparency Report this year has undergone:

Third party assurance over selected responses from this year’s PRI Transparency Report

Third party assurance over data points from other sources that have subsequently been used in your PRI responses this year

Third party assurance or audit of the correct implementation of RI processes (that have been reported to the PRI this year)

Internal audit of the correct implementation of RI processes and/or accuracy of RI data (that have been reported to the PRI this year)

Internal verification of responses before submission to the PRI (e.g. by the CEO or the board)

Whole PRI Transparency Report has been internally verified

Selected data has been internally verified

Other, specify

None of the above

01.2. Additional information [OPTIONAL]

CM1 02. Assurance of last year's PRI data

02.1. We undertook third party assurance on last year’s PRI Transparency Report

Whole PRI Transparency Report was assured last year

Selected data was assured in last year’s PRI Transparency Report

We did not assure last year's PRI Transparency report

None of the above, we were in our preparation year and did not report last year.

02.3. Additional information [OPTIONAL]

CM1 03. Other confidence building measures

03.1. We undertake confidence building measures that are unspecific to the data contained in our PRI Transparency Report:

We adhere to an RI certification or labelling scheme

We carry out independent/third party assurance over a whole public report (such as a sustainability report) extracts of which are included in this year’s PRI Transparency Report

ESG audit of holdings

Other, specify

None of the above

03.5. Additional information [OPTIONAL]

CM1 04. Assurance of this year's PRI data

04.1. Do you plan to conduct third party assurance of this year's PRI Transparency report?

Whole PRI Transparency Report will be assured

Selected data will be assured

We do not plan to assure this year's PRI Transparency report

04.3. Additional information [OPTIONAL]

CM1 05. External assurance (Not Applicable)

CM1 06. Assurance or internal audit

06.1. Provide details of the third party assurance of RI related processes, and/or details of the internal audit conducted by internal auditors of RI related processes (that have been reported to the PRI this year)

What RI processes have been assured

Data related to RI activities

RI policies

Specify

          SWEN CP Responsible Investment Policy

RI related governance

Engagement processes

Manager selection process for externally managed assets

Manager appointment process for externally managed assets

Manager monitoring process for externally managed assets

ESG incorporation in selection process for private equity investments

Other

When was the process assurance completed(dd/ mm/yy)

05/03/2019

Assurance standard used

IIA’s International Standards for the Professional Practice of Internal Auditing

ISAE 3402

ISO standard

AAF 01/06

SSE18

AT 101 (excluding financial data)

Other

Specify

          No specific standard used. The audit conducted on ESG issues has been made by the Compliance Officer (holder of the RCCI professional certificate delivered by the "French Market Authority") and the Risk Management Officer. They are both independent from the investment team and ESG analysts.

06.2. Additional information [OPTIONAL]

CM1 07. Internal verification

07.1. Indicate who has reviewed/verified internally the whole - or selected data of the - PRI Transparency Report . and if this applies to selected data please specify what data was reviewed

Who has conducted the verification

CEO or other Chief-Level staff

Sign-off or review of responses

Sign-off

Review of responses

The Board

Investment Committee

Compliance Function

RI/ESG Team

Investment Teams

Legal Department

Other (specify)

07.2. Additional information [OPTIONAL]

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